数字经济下营业利润征税权分配规则改革的经济学基础:从传统向当代的转捩

On the Economic Foundations of Allocation Rules Reform of Taxing Rights over Business Profits under the Digital Economy:The Transformation from Traditional to Contemporary Era

随着数字经济的飞速发展,营业利润方面的税收受到较严峻挑战。传统营业利润征税权分配规则得到包括传统受益和量能课税理论、经济忠诚原则和供应利润观等多项经济学基础的有力支撑,与前数字经济时代的时空条件相契合。但随着数字经济时代的到来,这些理论无论面对数字技术和数字经济发展,还是面对该领域相应规则及其架构的变革,均存在一定的不适应性,因而有必要对其予以革新。当前营业利润征税权分配规则及其变革的经济学基础则主要包括新受益理论、价值创造理论及有限度的供需利润观,系对早先传统规则经济学基础的重大变革。由此需要对这三条进路妥加调适,形成统合互补、有利于税改的良性格局。

As the digital economy develops rapidly,the taxation over business profits is challenged severely.The traditional allocation rules of taxing rights over business profits are strongly supported by several economic foundations such as traditional benefit and ability-to-pay principle,economic allegiance principle and supply-based approach,which is in accordance with the spatial and temporal conditions of the pre-digital-economy era.However,as the digital economy era arrives,in the face of the development of digital technologies and digital economy,as well as the corresponding rules and structure changes,there is certain inadaptability in the theories mentioned above.Therefore,it is necessary to transform them.The current economic foundations of allocation rules of taxing rights over business profits and their reform mainly include new benefit principle,value creation theory and limited supply-demand-based approach,which are great changes of economic foundations of previously traditional rules.Thus,we should adjust these three approaches appropriately in order to realize a healthy situation of integration and complementation in favor of tax reform.